Blanket Sanction Fatal: Tribunal Strike Down 153A Orders

Sanjay Garg Vs DCIT (ITAT Delhi)

Assessee challenged assessments framed u/s 153A r.w.s. 143(3) on the ground that mandatory approval u/s 153D was granted mechanically without proper application of mind. AO had made an addition of Rs.50,00,000/- as unexplained money u/s 69, which was confirmed by CIT(A)-24, New Delhi vide order dated 28.02.2025.

Before Tribunal, it was contended that JCIT had granted common approval for multiple years in a routine manner on the same day, which was humanly impossible & contrary to law. Reliance was placed on Delhi High Court in PCIT Vs Shi

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